John Huffman 

President and 

Chief Executive Officer 

Ms. Cecily Beall 

District Department of the Environment 

Air Quality Division 

1200 First Street, N.E., 5th floor 

Washington, D.C. 20002 

epco 

Energy Services 

August 30, 2010 

Re: District of Columbia Proposed Regional Haze State Implementation Plan 

Dear Ms. Beall: 

Pepco Energy Services, Inc. ("PES") appreciates this opportunity to comment upon the proposed 

District of Columbia Regional Haze State Implementation Plan ("SIP") final draft dated July 14, 

20 I 0 prepared by the Government of the District of Columbia, District Department of the 

Environment ("DDOE"). Potomac Power Resources, LLC ("PPR"), a wholly owned subsidiary 

of PES, owns the Benning Road Generating Station ("BRGS"), which was specifically discussed 

in the SIP. PES manages the assets of BRGS on behalf of PPR. PES is a wholly owned 

subsidiary of Pepco Holdings, Inc. 

BRGS consists of two oil-fired steam generators, Units 15 and 16, which operate to produce 

electricity. Units 15 and 16 were installed in 1968 and 1972, respectively. BRGS is scheduled to 

be retired and shut down on June 1,2012, and in coordination with the SIP, PES has agreed to a 

legally enforceable permit condition requiring a shut down of BRGS on or before December 17, 

2012, subject to the terms and conditions referred to in the SIP ("required shut down date"). We 

understand that the permit condition described in the SIP will be reflected in the Title V air 

permit currently being drafted by the DDOE for review by PES. 

This letter acknowledges PES' support of the proposed SIP rules concerning BRGS. See, 

generally, Section 9.6. In particular, PES agrees with the exemption ofBRGS from eligibility 

for Best Available Retrofit Technology ("BART") Section 169A of the Clean Air Act as 

described in Section 9.6.4. PES agrees that the Title V pelmit condition requiring closure of 

BRGS by December 17,2012 is sufficient to exempt BRGS from BART. The required shut 

down date will occur not later than 5 years after the SIP would have been due to be approved by 

the Environmental Protection Agency. In other words, closure ofBRGS by December 17,2012 

renders the BRGS exempt from the BART requirement. PES is pleased that the retirement of 

BROS meets the intent of the Regional Haze Rule. In addition, the emission reductions achieved 

by closure ofBRGS will contribute to the progress goals established in the Mid-Atlantic and 

Northeast - Visibility Union's ("MANE-VD's") long-term strategy. 

1300 North 17th Street· Suite 1600 • Arlington· /ljI. 22209 • 703-253-1753 • Fax 703-253-1803 • www.pepcoenergy.com 

Pepco Ellergy Services, Inc. is not the same company as Potomac Electric Power Company (Pepco), the regulated 

utility, and prices alld services of Pepco El1e7gy Services, Inc. are not set by the Public Service Commission. 
Ms. Cecily Beall 

August 30, 2010 Page 2 

As a result of the retirement ofBRGS that was announced in 2007, PlM and the affected 

transmission and distribution owners identified a number of necessary upgrades to the 

transmission and distribution system to compensate for the shut down of the BRGS. However, 

in the unlikely event that these upgrades are not completed on a timely basis or if electric loads 

were to grow at a significantly higher pace than expected, it is possible that BRGS would be 

required to remain open after the scheduled retirement date, and possibly beyond December 17, 

2012. Should the BRGS remain open after December 17,2012, PES acknowledges that BRGS 

would be subject to a de minimis cap on actual emissions ofPMlO of 15 tons per year as 

identified in the SIP, as will also be specified in the Title V air permit. 

PES respectfully disagrees that its BART analyses provided in October 2008 and April 2009 

were insufficient. However, provided that BRGS is treated as described in the proposed SIP, 

PES will not contest the asserted insufficiency of the BART analyses. 

Sincerely,